Georgia

Non-resident enterprises earning income from Georgian sources, other than through a PE, are subject to WHT at the following rates:

Payments of interest, royalties, or other Georgian-source income to non-residents registered in so called ’black listed’ countries are subject to WHT at a 15% rate.

The list of such countries is determined by the MoF of Georgia.

Double tax treaties (DTTs)

For those countries with which Georgia has entered into DTTs, the WHT rates are the following:

Notes

1. Some agreements provide a 0% rate on the interest paid by the government or any of its units or on the interest guaranteed by them or dividends paid to the government; this table doesn’t consider such provisions.
2. The 0% rate applies if the foreign company owns at least 50% of the Georgian company and has invested more than 2 million euros (EUR)/US dollars (USD).
3. Royalty rate paid for the enterprise is 5%.
4. The 0% rate refers to the copyright of any literature, art, or scientific works (except software), and films and records; the 5% rate refers to lease of techniques.
5. N/A
6. The 0% rate applies if the foreign company owns at least 50% of the Georgian company and has invested more than EUR 3 million.
7. The 0% rate applies if the foreign company owns at least 50% of the Georgian company and has invested more than 2 million pound sterling (GBP).
8. The 0% rate applies if the foreign company owns at least 25% of the Georgian company in any continuous 12-month period prior to distribution of dividends.
9. The 0% rate applies if the foreign company controls at least 50% of the voting power in the Georgian company and has invested more than EUR 2 million.
10. N/A
11. The 0% rate applies if the foreign company has invested in the Georgian company more than 3 million United States dollars (USD).
12. The 0% rate applies if the foreign company owns at least 10% of the Georgian company.
13. The 0% rate applies if the foreign company owns at least 10% of the capital or the voting power of the Georgian company.
14. Domestic WHT rates are applicable when a treaty provides a relief with more unfavourable rates.
15. Domestic WHT rate on dividends is 5%. A treaty provides a relief with the same or more unfavourable rate, thus the domestic rate is applicable.
16. Effective date for the treaties with Poland and Kyrgyzstan is 1 January 2024.
17. The 0% rate applies if the beneficial owner is a company (other than a partnership) that is a resident of the other state and directly holds at least 50% of the capital of the company paying the dividends.